D. Developing Effective Lines of Communication

1. Access to the Compliance Officer An open line of communication between the compliance officer and the billing company personnel is equally important to the successful implementation of a compliance program and the reduction of any potential for fraud, abuse and waste. Written confidentiality and non-retaliation policies should be developed and distributed to all employees to encourage communication and the reporting of incidents of potential fraud.77 The compliance committee should also develop several independent reporting paths for an employee to report fraud, waste or abuse so that such reports cannot be diverted by supervisors or other personnel. The OIG encourages the establishment of procedures for personnel to seek clarification from the compliance officer or members of the compliance committee in the event of any confusion or question regarding a company policy, practice or procedure. Questions and responses should be documented and dated and, if appropriate, shared with other staff so that standards, policies, practices and procedures can be updated and improved to reflect any necessary changes or clarifications. The compliance officer may want to solicit employee input in developing these communication and reporting systems.

2. Hotlines and Other Forms of Communication The OIG encourages the use of hotlines 78 (including anonymous hotlines), e-mails, written memoranda, newsletters and other forms of information exchange to maintain these open lines of communication.79 If the billing company establishes a hotline, the telephone number should be made readily available to all employees and independent contractors, by circulating the number on wallet cards or conspicuously posting the telephone number in common work areas.80 Employees should be permitted to report matters on an anonymous basis. Matters reported through the hotline or other communication sources that suggest substantial violations of compliance policies, Federal, State or private payer health care program requirements, regulations or statutes should be documented and investigated promptly to determine their veracity. A log should be maintained by the compliance officer that records such calls, including the nature of any investigation and its results.81 Such information should be included in reports to the governing body, the CEO and compliance committee.82 Further, while the billing company should always strive to maintain the confidentiality of an employee’s identity, it should also explicitly communicate that there may be a point where the individual’s identity may become known or may have to be revealed.

The OIG recognizes that assertions of fraud and abuse by employees who may have participated in illegal conduct or committed other malfeasance raise numerous complex legal and management issues that should be examined on a case-by-case basis. The compliance officer should work closely with legal counsel, who can provide guidance regarding such issues.

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